3 ms·

The terminology is confusing. Under the PPWR, a “producer” is not necessarily someone who manufactures packaging. The regulation also covers businesses selling

The terminology is confusing. Under the PPWR, a “producer” is not necessarily someone who manufactures packaging. The regulation also covers businesses selling packaging or packaged products directly to end users in another Member State. So a maker shipping a board in an envelope can indeed be the packaging producer for EPR purposes.

IsTom 1mo ago
Having looked into FAQ[1] it seems that it's mostly the case if you sell in branded packaging and are >10 people or >2M eur revenue. [1]https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1 https://op.europa.eu/en/publication-detail/-/publication/ad1...
- kakoni 1mo ago
  According to the PPWR rules, if you (as a webshop) package your shipment in non-branded box and send it from another EU country to another, then you are considered to be manufacturer(=you were the first to bring this into market) and EPR/PPWR rules apply. There is no exemption for this.
  - anigbrowl 1mo ago
    I'm more inclined to believe the person who backed up their argument with a citation, especially after looking at the document they linked which expressly contradicts you.
    - kakoni 1mo ago
      Sorry, messed up the terms here. You became producer. From the earlier faq that parent posted; > The following provide some typical examples of who the producer of transport packaging is: - If Company A fills the cardboard boxes and sells them to an end user in another Member State, then Company A would typically be the producer in that other Member State.
      - IsTom 1mo ago
        In the following > If Company A manufactures cardboard boxes under the name or trademark of Company B, then Company B will typically become the manufacturer and producer of the boxes in that Member State. However, if Company B is a micro-enterprise, then Company A is manufacturer and the producer in the Member State. That has the same "typically", so I'd assume it has the same micro-enterprise exemption. Otherwise only branded boxes would be exempt and that'd be pretty weird.

IsTom 1mo ago

Having looked into FAQ[1] it seems that it's mostly the case if you sell in branded packaging and are >10 people or >2M eur revenue. [1]https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1 https://op.europa.eu/en/publication-detail/-/publication/ad1...

kakoni 1mo ago
According to the PPWR rules, if you (as a webshop) package your shipment in non-branded box and send it from another EU country to another, then you are considered to be manufacturer(=you were the first to bring this into market) and EPR/PPWR rules apply. There is no exemption for this.
- anigbrowl 1mo ago
  I'm more inclined to believe the person who backed up their argument with a citation, especially after looking at the document they linked which expressly contradicts you.
  - kakoni 1mo ago
    Sorry, messed up the terms here. You became producer. From the earlier faq that parent posted; > The following provide some typical examples of who the producer of transport packaging is: - If Company A fills the cardboard boxes and sells them to an end user in another Member State, then Company A would typically be the producer in that other Member State.
    - IsTom 1mo ago
      In the following > If Company A manufactures cardboard boxes under the name or trademark of Company B, then Company B will typically become the manufacturer and producer of the boxes in that Member State. However, if Company B is a micro-enterprise, then Company A is manufacturer and the producer in the Member State. That has the same "typically", so I'd assume it has the same micro-enterprise exemption. Otherwise only branded boxes would be exempt and that'd be pretty weird.